Email to a law student interested in international tax


Posted by:
Phil Hodgen

Written on:
June 2, 2012

Posted in:
Random
Tax lawyers only

I received an email from a third-year law student interested in international tax. I’m in Dubai and coming home next week to a mountain of work and intend to (1) be with my family; (2) be in the office working; and (3) run laps around the Rose Bowl. Nothing else until my vacation at the end of June. No time. So I emailed him, and figured I’d post my email to him here, too. Do with it what you want.

Thanks for the email. Currently I am traveling in the Middle East and won’t be back until next week. When I get back I will be up to my eyeballs in work. Time is extremely tight for me, so emails — at least until November — are a better way to do this. Emails can sneak into the seams of time and get handled that way.

LL.M in Tax

All I can tell you is what I did. I did a tax LL.M. part-time at night from University of San Diego. I started the program thinking I would burnish my resume (I was an associate at a law firm at the time) and ended when I was self-employed, after being laid off from Security Pacific Bank following its acquisition by Bank of America. I completed the degree just for the psychological benefit of finishing something I had started.

The academic exercise of the LL.M was useful to me in only one sense — it gave me a force-feeding of information so my brain could start to connect dots. International tax is exceedingly complex because it requires knowledge of a complicated area of the Internal Revenue Code as well as other areas. Almost every problem is “international plus corporate” or “international plus partnership” or “international plus individual” etc. Sometimes, there are multiple overlays of complexity: individual plus corporate operating in the international context.

You’ll notice I did not mention the complexity added when you have multiple tax jurisdictions operating in a client’s life.

Or human elements of tension in the family or the business. Or questions of immigration and nationality — where will I live and where will my children grow up? These factors are outside the Internal Revenue Code but exponentially more important.

That said, you can replicate that deep tax code knowledge. Quicker and better than the LL.M. Take the advice of Derek Sivers. http://sivers.org/kimo

A tax LL.M will get you a job. Better to aim for mastery. http://gapingvoid.com/2012/05/31/on-mastery/

I am now 30 years out of law school. In some areas I think I am there — the subject matter is almost like playing. It’s fun and deeply satisfying. In other areas, I am a neophyte. I now stay away from these things unless I am willing to become a master. Be the best, link to the rest, as Jeff Jarvis says. http://buzzmachine.com/2007/02/22/new-rule-cover-what-you-do-best-link-to-the-rest/

Law school itself

The academic exercise of going to law school had a negative value for me. I don’t use anything I learned there in my real life. Perhaps that is too harsh. There must be some information and abstract knowledge implanted deep in my brain that is useful.

But law school itself? Meh. It is a three-year hazing ritual endured by generations past, so we must inflict it on those who follow us. Useless.

Action

Enough ranting. Let’s talk concrete action. If I took my 56 year old brain and put it into my 26 year old body, what would I do?

1. Sit down and read Rhoades and Langer from cover to cover. Then start reading BNA Portfolios one at a time. Just read. Focus as you wish — inbound or outbound, corporate or individual. Just absorb. I wouldn’t even necessarily try to understand at that stage. Just absorb.

2. Start doing. You will learn 1,000X by doing rather than reading. Don’t do this without a net, though. There are clients whose well-being is in your hands.

3. See where it goes. Don’t think you can control and enjoy your life. You can have one or the other. :-) Not both.

Amplification

Step 2 contains two items that are hard: getting projects, and getting a net.

One is the doing part. How can you “do” if you don’t have any projects? Two ways. You create clients or you go somewhere (like a job) where clients are already there and work on their projects.

The 26 year old Phil’s brain blocked the second pathway (go where the projects are, and learn) by demanding a high salary. “Don’t you know who I am? Etc.” I stunted my growth by greed and ego. My 56 year old brain would tell my 26 year old self to not make this mistake again. Be humble.

And how do you get a net? A net is a human being who knows more than you will ever know, so when you’re around that person you shut up and hang around and learn stuff.

How do you find this person? Again you can either do it freestyle or in the job context.

Either way, people call this a “mentor.” Showing up and saying “mentor me” is not the way to go. You can find endless stuff on the interwebs about this. Find a way to do this.

All I can tell you is my opinion. Consider it from your would-be mentor’s side of table. He/she is extremely busy doing stuff that is extremely interesting to him/her. He/she probably also has a family and friends. You have to dislodge something existing in that person’s life to create an opening for you.

You will have to be so extremely interesting to your mentor that you’ll be more important than your mentor’s child.

The easiest way to be extremely valuable to your would-be mentor is to create time. They can use this time to do whatever is most valuable to them. I commend John Carlton’s perspective to you on this point. Read a ton of his blog posts. http://www.john-carlton.com/

Finally

Finally, I leave you with a light-hearted but entirely and deeply important message. Heed Jeff Atwood’s admonition to embrace the suck. http://www.slideshare.net/codinghorror/how-to-stop-sucking-and-be-awesome-instead

Email to a law student interested in international tax by
  • http://taxdood.com Brad P

    Great points, Phil.

    Would like to expand on the following: “You have to dislodge something existing in that person’s life to create an opening for you.”

    From my (limited) experience as a fellow tax lawyer, one way to accomplish this is to develop an expertise in a niche within tax. When you bring something to the table that others don’t, people become interested in you.

    It’s a three step process:

    1. Articulating and then learning the niche. (lots of brainstorming and research involved) The niche should probably be an underdeveloped area of the tax law that has significant room for growth.

    2. Writing about it (a blog is one way to start, followed by contributing articles to other blogs, periodicals, etc.). Here, you develop the reputation of having an expertise in the niche.

    3. Using the reputation to create connections with the far more experienced practitioners who may already have clients impacted (or about to be impacted) by this niche.

    This process takes time. There are no shortcuts. But it’s an exciting and potentially very rewarding journey. For someone looking to break into tax law (or any other area of law, really), I highly recommend giving it a fair shot.

    • http://hodgen.com/ Phil

      Thanks Brad. Yes, the blogging and specialization process can work too.

      Your point about time is a key one. It takes a long time to master anything. Including tax.

  • John

    As a 2010 NYU Tax LLM, I agree with this post. The only change is that a tax a LLM does not get you a job in this market–many of my friends were struggling to find an offer anywhere. I was very lucky to get a singular, non-plural offer, and I still consider myself very lucky to be where I am.

    Without nitpicking my year at NYU, I’ll say it was easily the best year of my four in law school. I worked harder, and consequently learned more, because NYU only allowed us to drink from the IRC at fire-hose volumes. Could I have learned the same things without spending a year there? Definitely, and the treatise + BNA plan is a good way to simulate that experience. But given the choice, I’d choose NYU again because I had the professors there to guide the process. Your mileage may vary.

    Finally, even though I have that nice piece of paper from NYU, that doesn’t get me anything in the real world, so I’m still working my way through the BNAs to keep learning.